Most Commonly Overlooked Fall Protection Hazards
Although most employers demonstrate the desire to exceed the minimum OSHA requirements, many others are satisfied with providing only the bare minimum of training and equipment with regards to fall protection for their employees, and in many cases, for themselves. Many rely solely on the information provided by the equipment distributor or the minimal training they have received, if any. It is ultimately the responsibility of the employer to ensure any employee exposed to fall hazards are not just trained on how to properly wear their body harness, but also the appropriate use of the equipment and any other hazards or potential hazards they may be exposed to when working at height. Examples would include, swing radius, proper clearance, equipment compatibility, proper connection of the equipment, which anchors are acceptable to use and are the anchors mounted or connected correctly.
I have seen it all, from employees actually tying lanyards together in a knot in order to widen their accessibility to other areas, to connecting their rope grabs to the end of the vertical life lines piled up on a roof, and even connecting lanyards to electrical conduit for use as an anchor. These are all prime examples of improper training, or the lack thereof.
The following are additional hazards encountered in both general and the construction industry that are commonly overlooked:
(1) 6 Foot Shock Absorbing Lanyards (SAL)
The 6’ SAL is probably the most common piece of equipment used for fall protection. However, I find that many employees who use this device do not actually understand the distance needed from anchor point to ground level (or lower level) to allow for safe clearance. Most SALs are 6’ long with a 3’ expandable pack and need approximately 12" to 18” of stretch and one foot of clearance. This does not include the average height of the person wearing the full body harness, by the time their weight has stretched out the harness, the D-ring is at about head height, therefore depending on the persons size, that would be an additional 6’, which would be a total of 17’ in all. (See diagram 1)
It would be best to do a job hazard analysis to determine whether or not this is the proper equipment for the job. This does not only apply to residential roofs, where a good number of employees are working well below the 17’ from anchor point to ground level, but also on higher roofs or work levels that may have a lower level, equipment, or vehicles within that distance.
(2) Order Pickers
An order picker is a piece of equipment mainly used in the warehousing and distribution industry. It consists of a powered platform on which the employer stands. The platform raises and lowers allowing the employee access to the stock on standard warehouse shelving. Most of the order pickers I have encountered are equipped with the standard 6’ SAL, anchored to the top of the platform at about 7’. The majority of the work being conducted is at the first level of the shelving which approximately 6’ from ground level. The problem is that those distances combined are about 13’-14’, but with that type of system you need at least 17’. Therefore, if an employee falls while working at lower levels they would still make contact with the ground. (See diagram 1)
A simple solution to this issue would be to replace the SAL with a self-retracting lifeline (SRL), which operates on a similar premise as a seat belt and in most cases are required to stop within 2’, but many stop much sooner. The SRL allows the employee to move around freely, but if for some reason they accelerate too quickly, such as falling or losing their balance, the lanyard will lock up and in most cases prevent the fall. However, SLRs are also designed to absorb the forces of the short fall allowed by its design, so it also qualifies as a fall protection device.
(3) Boom lifts
I am asked often about boom lifts and fall protection, many of the questions are centered on the need for a personal fall arrest system (PFAS) due to having the sides of the bucket or cage to protect them. Which is a good point, but the need for a PFAS when using this equipment is not just for falls, but mostly for ejections. Although employees working with these are normally well above 17’ from anchor to ground level, if using a SAL, which is very commonly, this could result in something similar to a sling shot if ejected. There is a good chance the employee might be directed right back onto the basket or arm of the device.
A better choice would be to use a SRL, because there is a good probability that the employee would never be ejected, but if they are, the SLR is still designed to absorb those impact forces and the weight of the employee.
(4) Swing Radius
Swing radius is probably the most commonly overlooked hazard in relation to fall protection. (See diagram 2). I have seen this hazard on residential roofs and even on commercial building. Individuals stretch out their equipment or life lines beyond its effective use, not realizing the danger they are placing themselves in if they do fall, which could result in not only making contact with ground, but possibly another level, another portion of the structure or a piece of equipment. This is possible not just with a 6’ SAL, but also a SRL, depending on how they are being used and how far away the anchor point is. Often this occurs during residential roofing when using vertical lift lines with rope grabs, the employee will exceed well beyond the angle in which they were designed to be used. (See diagram 2)
The most appropriate solution to this issue is training. As an employer, you need to know the risks or potential hazards and convey that information to the employees through training, safety meetings and other means of communication. This can be accomplished through verbal or written tests or simply asking questions during meetings.
(5) Improper type and use
I have seen employees working on residential roofs with heavy steel erection type harnesses, daisy chaining lanyards, and wearing body harnesses way too small or too big. This again is the result of the employer not providing the proper equipment or training.
Employers and employees are not expected to be experts in the technical facts related to fall protection equipment, which is why you should always defer to the manufacturer’s requirements and recommendation. This information should be provided when you purchase the equipment or can easily be accessed through the manufacturer’s website. If you have any doubts, call the manufacture for clarification to ensure your employees’ safety is not placed at risk.
The following are some questions you might want to ask yourself or the distributor before purchasing any fall protection equipment: • Should I be using a SRL or a SAL? • Is this really the right SRL for the job? • Is it too big or too small? • Is this lanyard and body harness compatible with each other and the anchor we are using? • Are these the right size and type of body harness I need for my workers? • Is this the right type of anchor I need for the work I am doing? • Has this anchor been connected correctly? • How can I tell when this equipment is beyond its effective/safe use? • How many employees is this life line designed for? • If this horizontal life line engineered? • Do my employees understand how to properly use the equipment?
For additional resources on fall protection:
OSHA’s Fall Protection Page
Fall Protection in Residential Protection
OSHA’s Educational Materials and Resources for Workers and Employers
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The USF OSHA Training Institute Education Center offers fall protection course on a regular basis. Visit www.usfoticenter.org to view the course schedule or to register to attend classes. Likewise, you may send an email to firstname.lastname@example.org for more information.